Lobbying and political contributions policy

Overview

ReGEN Strategic and its associated entities (the Company) are committed to operating with integrity in dealing with both government, political parties and their representatives. The Company is also committed to building and maintaining confidence in both the political process and lobbying’s role within that process.

The Company will act in accordance with this policy in relation to the political involvement of its workers, as well as lobbying activities undertaken on behalf of the Company’s clients and the political contributions of both the Company, its workers and its clients.

This policy:

explains the concepts of political involvement, lobbying and political contributions;
explains the approach of the Company to maintaining confidence in the lobbying process;
explains the approach of the Company to ensuring lobbying activities undertaken are in support of the both the Sustainable Development Goals and the Paris Agreement;
explains the approach of the Company to political contributions and reporting on political contributions;
outlines what behaviour is expected of workers; and
sets out the steps that can be taken if a worker considers that this policy has been breached.

This policy complements the Company’s Code of Conduct.

Scope of this policy

This policy applies to all workers of the Company.

Workers engaged by the Company must always comply with this policy during their engagement by the Company. However, this policy does not form part of any person’s contract with the Company or create any enforceable rights or entitlements for them.

Failure to comply with this policy is likely to lead to the Company taking disciplinary action against a person, which may include termination of the person’s engagement by the Company.

This policy applies in the workplace when it happens:

at work
at work-related events
between people sharing the same workplace
between colleagues outside of work
between employees and any other people connected with work (such as clients or service providers).

To avoid doubt, ‘work related events’ include, but are not limited to:

work-related social events and functions
general social events, such as drinks with work colleagues after work
conferences
business and field trips
training programs, and
business or client functions.

The policy also applies to conduct on social media or conduct using the Company’s IT (computer, email and internet) system. Please refer to and read this policy in conjunction with the Company’s Social Media Policy and IT/Computer Use Policy.

Who is a ‘worker’?

In this policy, a ‘worker’ of the Company means any person who carries out work in any capacity for the Company, including work as:

an employee
a manager
an employee of a labour hire company who has been assigned to work in the Company (i.e. a ‘temp’)
a contractor that provides services to the company that are on-sold to clients
an apprentice or trainee
a student gaining work experience, or
a volunteer.

The policy also applies to persons who would be ‘agents’ of the Company for whose conduct the Company could be vicariously liable under applicable legislation.

Political involvement

The International Covenant on Civil and Political Rights can into force on 23 March 1976. Australia ratified this covenant in 1980.

Article 22 of this covenant provides every citizen with the right, “to freedom of association with others”. Article 25 of this covenant further provides every citizen with the right and opportunity, “to take part in the conduct of public affairs”.

Through these rights, the Company’s workers have the right to join and participate in the activities of their political party of choice. Beyond these rights, the Company views the participation of individuals as important to the healthy functioning of the democratic process, as well as the achievement of the United Nations Sustainable Development Goals, including Goal 16 on Peace, Justice and Strong Institutions.

However, it is noted that the various laws, regulations and codes of conduct implemented by governments across Australia (see Appendix A) may prohibit those undertaking lobbying activities from holding positions within a political party at certain levels of seniority. This is designed to avoid real or perceived conflicts of interest.

Lobbying activities

Lobbyists can enhance the strength of our democracy by assisting individuals and organisations with advice on public policy processes and facilitating contact with relevant government representatives. As such, lobbying is accepted as an important and legitimate part of the political process.

Lobbying is often undertaken directly by individuals and organisations with government. However, in some cases, individuals and organisations engage consultants to lobby government on their behalf.

Lobbying is a service provided to the Company’s clients through its government relations service in its stakeholder engagement practice. To realise the Company’s purpose of making ESG easy for its clients and maximising their environmental and social impact, effective engagement with both the government and opposition parties is essential. This can include attendance at networking or informational events organised by political parties.

However, the Company acknowledges that a lack of transparency over lobbying activities can undermine public confidence in the political system.

Various laws, regulations and codes of conduct have been implemented by governments across Australia to strengthen the integrity of lobbying activities. A list of these is provided in Appendix A to this policy.

Political contributions

Political contributions are defined by the Global Reporting Initiative standard GRI 415: Public Policy 2016 in the following ways.

Financial contributions

Donations, loans, sponsorships, retainers or the purchase of tickets for fundraising events.

In-kind contributions

Advertising, use of facilities, design and printing, donation of equipment, or the provision of board membership, employment or consultancy work for elected officials, politicians or candidates for office.

Indirect political contributions

Financial or in-kind support to political parties, their representatives, or candidates for office made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.

The Company recognises the role political donations can play in the healthy functioning of the democratic process through the funding of election campaign activities that build voter awareness of the policies of political parties and encourage voter engagement.

However, the Company acknowledges that a lack of transparency over political contributions can undermine public confidence in the political system, and can undermine the pursuit of the United Nations Sustainable Development Goals.

The company also acknowledges that the real or perceived favouring of one political party over others in the making of political contributions can create perceptions of partisanship, create barriers to effective engagement with political stakeholders and thereby undermine the Company’s purpose of making ESG easy for its clients and maximising their environmental and social impact.

Various laws and regulations have been implemented by governments across Australia in relation to the making of political contributions (see Appendix B).

Compliance with this policy

All workers may join a political party of their choice, participate in activities, make personal political contributions and hold positions of seniority that are not prohibited by any laws, regulations or codes of conduct implemented in Australia in relation to lobbying activities (see Appendix A).

The Company and its workers will comply with the provisions of all legislation, regulations or codes of conduct implemented in Australia in relation to lobbying activities (see Appendix A). The Company will further make its clients aware of these requirements and encourage their compliance.

The Company and its employees will not undertake lobbying activities for companies that:

Derive revenue from the extraction of fossil fuels and cannot credibly demonstrate how they are contributing to the goals of the Paris Agreement;
Seek to undermine the achievement of the United Nations Sustainable Development Goals; or
Seek to greenwash their performance on Climate Action or other Sustainable Development Goals with stakeholders.

The Company and its workers will comply with the provisions of all Australian laws and regulations governing the making of political contributions (see Appendix B). The Company will further make its clients aware of these requirements and encourage their compliance.

The Company will not allow itself to be used by its clients to make indirect political contributions.

The Company will not make donations to any political party or candidate for election.

The Company’s political contributions will be limited to re-imbursing its workers for the purchase of tickets for networking or informational events organised by political parties to the value of $300 per ticket, on the condition that the event is approved within the networking plan of the relevant worker. The Company will use its best endeavours to ensure that it is engaging with both government and opposition parties through this process.

In its annual sustainability report, the Company will report:

The clients for which it has undertaken lobbying activities for in the previous 12 months.
The number of breaches of any laws, regulations or codes of conduct relating to lobbying or political contributions that the Company has been found by the relevant authority to have made, the details of any breaches and any measures the Company has put in place to ensure the breaches do not occur again.
The total monetary value of any political contributions made, in alignment with Global Reporting Initiative standard GRI 415: Public Policy 2016 or any relevant, updated standard.
The total number of networking or informational events the Company has reimbursed workers for attending, broken down by political party.

In all the above, workers must comply with the Company’s Code of Conduct and all other Company policies.

Responsibilities

It is the responsibility of everyone covered by this policy to:

ensure they familiarise themselves with the terms of this policy and comply with it, and
act in a way which sets an example for other workers by ensuring their conduct in the workplace complies with this policy,

Managers

Without in any way limiting the other provisions of this policy, all managers must:

exercise due diligence to ensure the Company complies with its obligations,
ensure they familiarise themselves with the terms of this policy, their responsibilities in relation to it and help employees to become familiar with this policy, and
act in a way which sets an example for other employees by conducting themselves in accordance with the terms of this policy.

Consequences of contravening the policy

If the Company is found to have acted in contravention of this policy, this information will be captured on and reported in the company’s annual sustainability report (see above).

If workers engage in conduct in contravention of this policy and/or applicable legislation, you will be subject to disciplinary action, up to and including possible termination of their engagement.

Appendix A: Political Lobbying

Lobbying Code of Conduct (Cth)

Foreign Influence Transparency Scheme Act 2018 (Cth)

Integrity (Lobbyist) Act 2016 (WA)

Code of Conduct for Registrants and Lobbyists 2016 (WA)

Lobbyist Act 2015 (SA)

Lobbyist Regulations 2016 (SA)

South Australia Lobbyist Code of Conduct 2014 (SA)

Integrity Act 2009 (Qld)

Lobbyists Code of Conduct (Qld)

Lobbying of Government Officials Act 2011 No 5 (NSW)

Lobbying of Government Officials (Lobbyist Code of Conduct) Regulation 2014 (NSW)

Public Administration Act 2004 (Vic)

The Victorian Government Professional Lobbyist Code of Conduct (Vic)

Integrity Commission Act 2009 (Tas)

Tasmanian Government Lobbying Code of Conduct 2022 (Tas)

ACT Lobbying Code of Conduct 2014 (ACT)

ACT Lobbyist Regulation Guidelines 2014 (ACT)

NT: does not have a Register of Lobbyists or any requirements for government relations practitioners to be registered.

Appendix B: Political Contributions

Commonwealth - Commonwealth Electoral Act 1918 (Cth)

NSW - Electoral Funding Act 2018 No 20 (NSW)

Vic - Electoral Act 2002 (Vic)

Qld - Electoral Act 1992 (Qld)

SA - Electoral Act 1985 (SA)

WA - Electoral Act 1907 (WA)

Tas - Electoral Act 2004 (Tas)

ACT - Electoral Act 1992 (ACT) and Electoral Amendment Bill 2018 (ACT)

NT - Electoral Act 2004 (NT) and Electoral Legislation Further Amendment Bill 2019 (NT)